Interpretation Response #02-0285 ([ArthurP. Hancock])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: ArthurP. Hancock
Country: US
View the Interpretation Document
Response text:
Nov 23, 1998
Arthur P. Hancock Reference No. 02-0285
42 Gorse Road
Cookham, Berks SL6 9LL
England
Dear Mr. Hancock:
This is in response to your facsimile of November 16, 1998, concerning a new requirement for limited quantities of dangerous goods introduced into the European road and rail regulations for transporting dangerous goods (ADR/RID). The new requirements (e.g., marginal 2301a of the ADR), which become effective on January 1, 1999, are for a diamond shaped label to appear on packages of limited quantities of dangerous goods. The label is to bear the United Nations number of the item of dangerous goods contained in the package or the letters "LQ" when more than one item of dangerous goods is in the package. You asked whether packages so labeled would be acceptable for transport in the United States.
We consider packages so labeled to be unacceptable for transport in the United States. The US Hazardous Materials Regulations (HMR) in Title 49 of the Code of Federal Regulations in 172.401(b) prohibits labeling "which by its color, design, or shape could be confused with a label prescribed" by the HMR. In our opinion, the labeling required by the new ADR/RID requirements could be so confused. Therefore, such labeling is prohibited from use in the United States.
Sincerely,
Frits Wybenga,
International Standards Coordinator
for Hazardous Materials Safety
172.401(b)
Regulation Sections
| Section | Subject |
|---|---|
| 172.401 | Prohibited labeling |